The document compares the current and future state of regulations regarding mortgage loan disclosures and closing processes. Some key changes in the future state include expanding the scope of covered transactions, requiring a single Closing Disclosure form to replace the HUD-1 and TILA forms, more restrictions on fee increases at closing, additional triggers requiring revised initial disclosures, and changes to timing requirements for delivery of disclosures to the borrower. The future state aims to increase consumer protections and align regulations with the new TILA-RESPA integrated disclosures.

1. TRID:
Current State vs Future State
Comparison

2. CURRENT STATE FUTURE STATE 10/3/15
COVERED TRANSACTIONS Federally related mortgage
loans: closed-end,
consumer purpose
transactions secured by
residential real property
with a 1-4 family residence
Closed-end, consumer
credit transactions secured
by real property (Does not
require a residential
structure however, RSM
does not do LOT loans at
this time.
EXEMPTIONS • Business purpose loans*
•Reverse Mortgages
•HELOCS*
•Lot loans*
•Loans secured by more
than 25 acres
•Construction Loans*
•Temporary , closed-end
consumer loans (i.e.,
Bridge Loans)*
•Credit extended to non-
natural persons (LLC’s,
Trusts, Estates)
* Not currently offered by
RSM
•Business purpose loans
•Reverse Mortgages
•HELOCS*
•Mobile home loans with
no land attached

3. CURRENT STATE FUTURE STATE 10/3/15
DEFINITION OF
APPLICATION
1. Name
2. Income
3. Social Security #
4. Property Address
5. Estimated Value
6. Loan Amount
7. Any other information
deemed necessary by
Lender (not applicable
for RSM)
1. Name
2. Income
3. Social Security #
4. Property Address
5. Estimated Value
6. Loan Amount
INITIAL DISCLOSURE(S) 1. Good Faith Estimate
2. Early Truth In Lending
1. Loan Estimate
DELIVERY TIMING Within 3 days of
application and at least 7
days prior to closing.
Same
ELECTRONIC DELIVERY Permitted if in compliance
with E-Sign Act
Same
BUSINESS DAY FOR 3 DAY
DELIVERY OF INITIAL
DISCLOSURES
All days Lender is open for
Business. For RSM this
does NOT include Saturday
Same

4. CURRENT STATE FUTURE STATE 10/3/15
BUSINESS DAY FOR 7 DAY
DELIVERY OF INITIAL
DISCLOSURE TO CLOSING
All calendar days except
Sunday and legal public
holidays
Same
SETTLEMENT SERVICE
PROVIDER LIST
Must be provided within 3
days of application
Same
FEE RESTRICTION Except for a Credit Report,
fees cannot be charged or
collected until disclosures
are provided and consumer
indicates Intent to Proceed
Same
PRE-APPLICATION
DISCLOSURE
Permitted but cannot look
like GFE
Permitted but cannot look
like LE or GFE and must
state in 12 POINT FONT on
top of 1st page: “Your
actual rate, payment, and
costs could be higher. Get
an official Loan Estimate
before choosing a loan”.

5. CURRENT STATE FUTURE STATE 10/3/15
REQUIRE VERIFICATION
DOCUMENTS
Prohibited until GFE is
provided and consumer
indicates Intent to Proceed.
Prohibited until LE is
provided and borrower
indicates Intent to Proceed.
PERMITTED FEE
INCREASES FROM INITIAL
DISCLOSURES (GFE & LE)
TO CLOSING DISCLOSURES
(HUD1 & CD)
Costs that CANNOT
increase from GFE to
HUD1:
1) Origination Charge
2) Once interest rate
locked:
 credit or charge for
interest rate chosen
 adjusted origination
charge
3) Transfer Taxes
Costs that CANNOT
increase from LE to CD:
1) Fees paid to lender or
mortgage broker
2) Fees paid to an affiliate
of lender or mortgage
broker
3) Transfer Taxes
4) Fees paid to an
unaffiliated 3rd party if
the lender did not
permit the borrower to
shop for the service.

6. CURRENT STATE FUTURE STATE 10/3/15
PERMITTED FEE
INCREASES FROM INITIAL
DISCLOSURES (GFE & LE)
TO CLOSING DISCLOSURES
(HUD1 & CD)
Costs that can increase in
the aggregate up to 10%:
1. Lender required, lender
selected settlement
providers.
2. Lender required
services, title services
and required title
insurance when the
borrower uses a
settlement service
provider identified by
the lender on the
settlement service
provider list.
3. Government Recording
charges
Costs that can increase in
the aggregate up to 10%:
1. Recording fees paid to
government.
2. Services the borrower
is permitted to shop for
and selects the
provider from the
settlement service
provider list.
3. Services the borrower
is permitted to shop for
and does NOT select a
provider
4. Services for which the
lender permits the
borrower to shop for
but fails to provide the
settlement service
provider list.

7. CURRENT STATE FUTURE STATE 10/3/15
PERMITTED COST
INCREASES FROM INITIAL
DISCLOSURES (GFE & LE)
TO CLOSING DISCLOSURES
(HUD-1 & CD)
Costs that can increase in
any amount:
1. Prepaid interest
2. Property insurance
premiums.
3. Amounts paid into
escrow
4. Charges paid to 3rd
party service providers
selected by borrower
that are not on the
lender’s written list.
5. Charges paid for 3rd
party services not
required by the lender.
Costs that can increase in
any amount:
1. Prepaid interest
2. Property insurance
premiums.
3. Amounts paid into
escrow
4. Charges paid to 3rd
party service providers
selected by borrower
that are not on the
lender’s written list.
5. Charges paid for 3rd
party services not
required by the lender.

8. CURRENT STATE FUTURE STATE 10/3/15
CHANGED
CIRCUMSTANCES
Categories of changed
circumstances:
1. Changed circumstances
affecting the
settlement fees.
2. Changed circumstances
affecting the loan
3. Borrower requested
changes
4. Expiration of the GFE
(10 business days) with
no Intent to Proceed.
5. Delayed settlement on
a construction loan if
notice is provided.
6. Interest rate dependent
charges.
Categories of changed
circumstances:
1. Changed circumstances
affecting the
settlement fees.
2. Changed circumstances
affecting eligibility.
3. Borrower requested
changes.
4. Expiation of the LE (10
business days) with no
Intent to Proceed.
5. Delayed settlement on
a construction loan if
notice is provided.
6. Interest rate dependent
charges.

9. CURRENT STATE FUTURE STATE 10/3/15
TRIGGER FOR REVISED
INITIAL DISCLOSURES
Good Faith Estimate:
1. Valid changed
circumstances that
result in increased
charges.
2. Locking in loan’s
interest rate.
3. Expiration of GFE with
no Intent to Proceed.
4. Permanent financing of
construction loan more
than 60 calendar days
after original GFE with
construction loan
disclosure.*
5. Change in any material
term of the loan.
TIL:
1. APR becomes
inaccurate by more
than .125%
Loan Estimate:
1. Valid changed
circumstances that
result in an increase of
any amount to “zero
tolerance” fees:
 A fee paid to the
lender, mortgage
broker or affiliate of
either.
 A fee for which the
borrower is not
permitted to shop for
 Transfer Taxes.

10. CURRENT STATE FUTURE STATE 10/3/15
TRIGGER FOR REVISED
INITIAL DISCLOSURES
*RSM currently does not
offer construction loans.
2. Valid changed
circumstance that
results in an increase in
the fees that fall into
the 10% category:
 Charges borrower is
permitted to shop for.
 Recording fees.
3. Locking loan’s interest
rate.
4. Expiration of LE with no
Intent to Proceed.
5. Within 60 days of the
original LE for a
construction loan, but
only when the original
LE clearly states the
new LE may be issued
prior to 60 days prior to
closing*

11. CURRENT STATE FUTURE STATE 10/3/15
TIMING OF REVISED
INITIAL DISCLOSURES
Good Faith Estimate:
Delivery within 3 business
days of receiving notice
that a changed
circumstance occurred.
TIL:
Received by borrower at
least 3 business days prior
to closing.
Loan Estimate:
Delivery within 3 business
days of receiving notice
that a changed
circumstance triggered
EXCEPT:
Revised LE cannot be
received by the borrower
on the same day the
borrower receives the
Closing Disclosure. Revised
LE must be received at
least 4 business days prior
to closing.
If delivering the revised
LE by means other than in
person, including
electronically, the
disclosure is considered to
rec’d 3 business days after
placing in mail unless
lender receives proof of
receipt.

12. CURRENT STATE FUTURE STATE 10/3/15
DEFINITION OF A
BUSINESS DAY FOR 3 DAY
REDISCLOSURE
A day on which the
lenders’ offices are open to
the public for substantially
all business functions. For
RSM, this does NOT include
Saturday.
Same
DEFINITION OF A
BUSINESS DAY FOR
PROVISION OF REVISED LE
OR “4 BUSINESS DAYS”
PRIOR TO CLOSING
N/A All calendar days EXCEPT
Sunday and the legal public
holidays.
CLOSING DISCLOSURES Two Disclosures:
HUDI Settlement
Statement and Final Truth
In Lending (TIL)
One Disclosure:
Closing Disclosure (CD)

13. CURRENT STATE FUTURE STATE 10/3/15
RESPONSIBLE PARTY FOR
ACCURACY OF CLOSING
DISCLOSURE
TIL – LENDER
HUD1 – SETTLEMENT
AGENT
CD – LENDER (Lender and
Settlement Agent may
agree to divide
responsibility for
completion, but Lender
remains the responsible
party.)
DELIVERY OF CLOSING
DISCLOSURE
1. Available for inspection
on business day prior
to closing with items
known to lender.
2. At or before closing.
1. Received by borrower
no later than 3 days
prior to closing.
2. Cannot be received by
borrower same day
revised LE is issued.
3. If delivering the CD
other than in person,
including electronically,
the disclosure is
considered to be rec’d
3 business days after
placing in mail unless
lender has proof of
receipt.

14. CURRENT STATE FUTURE STATE 10/3/15
DEFINITION OF “BUSINESS
DAY” FOR DELIVERY OF
CLOSING DISCLOSURES
All calendar days except
Sundays and legal public
holidays
Same
ELECTRONIC DELIVERY Permitted-but must comply
with E-Sign Act
Same
CLOSING DISCLOSURE FEE
RESTRICTION
No fee may be imposed for
preparation of disclosure
Same

15. CURRENT STATE FUTURE STATE 10/3/15
SUBSEQUENT CHANGES
TO CLOSING DISCLOSURES
An inadvertent or technical
error in completing the
HUD-1 or HUD-1A
 Provide a revised HUD-
1 or HUD-1A within 30
calendar days of closing
Changes BEFORE closing
requiring a revised CD AND
NEW 3-BUSINESS DAY
waiting period:
The disclosed APR is
found to be inaccurate by
increasing more than
.125%
The loan product
changes
A prepayment penalty
has been added.
Changes BEFORE closing
requiring revised CD at or
before closing but NO new
waiting period:
Any change other than
those described above.
•Revised CD MUST be
available day before closing
if requested by borrower

16. CURRENT STATE FUTURE STATE 10/3/15
SUBSEQUENT CHANGES
TO CLOSING DISCLOSURES
Changes FOLLOWING
Closing requiring revised
CD:
Events that cause a
change to the amount paid
by the borrower within 30
calendar days of closing.
•Within 30 calendar days
after receipt of change
information.
Non-numeric clerical
errors
•Within 60 calendar days
after closing

17. CURRENT STATE FUTURE STATE 10/3/15
TOLERANCE VIOLATIONS
(CURE)
Not deemed a section 4
violation IF:
A revised HUDI or HUDIA
is provided.
Amount is refunded to
borrower within 30
calendar days after closing.
Not deemed a violation IF:
A revised CD is provided
Amount is refunded to
borrower within 60
calendar days after closing.